In recent years, the ITC has coordinated extensively with EPA and other
Federal Agencies in identifying their specific testing and data needs. For
example, in recent ITC reports, approximately 80 chemicals were designated
for dermal absorption rate testing to support a data need of the Occupational
Safety and Health Administration (OSHA). Chemicals that are formally designated
by ITC to EPA to develop testing actions are immediately added to OPPT's
MTL and can be added to automatically effective TSCA Section 8(a)
and 8(d) rules to gather data to support
development of that testing action. Chemicals that are recommended by the
ITC for testing are not immediately added to OPPT's MTL
but are ususally made subject to automatically effective Section 8(a)/8(d)
rules to gather data to support an ITC decision to formally designate a
chemical to EPA for testing action development.

The statute specifies that EPA should give priority consideration to chemical
that the ITC places on its TSCA Section 4(e) "Priority Testing List" and
initiate a "proceeding" within 12 months. The significant time and resource
burden on EPA to develop formal test rules under Section 4 of TSCA has
not allowed this to occur except in rare instances. Two major lawsuits
have provided guidance in this area but have not lessened EPA's burden
to any great extent. As a result, EPA has developed and currently utilizes
other types of testing action "tools" in order to obtain needed test data.